Mitigating Risk and Navigating Interdependencies in

Defense Industry Compliance

Thursday, February 24, 2005

About

When your primary customer is the federal government, there are no "minor" compliance concerns.

In the face of increased enforcement activity, as well as mounting Pentagon and congressional scrutiny, industry compliance-robust, effective compliance-matters more than ever. In a contentious national environment over sharply increased defense spending for the war in Iraq, it can help insulate your company against media and public criticism of DoD procurement practices. In addition, post 9/11, the heightened focus on security and anti-terrorism measures makes effective compliance a matter of national concern.

But the relevant regulations and statutes intersect in myriad, unexpected ways, as does their enforcement. Multiple agencies with conflicting priorities are involved and lines of jurisdiction are often blurred. Interpretative guidance from the policy makers often leaves you with few resources for figuring out how to best comply. Equally troubling enforcement "wildcatting" often means that an investigation of an export controls violation by one agency may lead to an FCPA investigation by another, and vice versa.

This makes devising an integrated approach to your company's compliance efforts vital. Failure to do so could come at a cost: damage to your company's reputation, diminished share value and potential exposure to significant civil and criminal penalties.

Contents & Contributors

About

When your primary customer is the federal government, there are no "minor" compliance concerns.

In the face of increased enforcement activity, as well as mounting Pentagon and congressional scrutiny, industry compliance-robust, effective compliance-matters more than ever. In a contentious national environment over sharply increased defense spending for the war in Iraq, it can help insulate your company against media and public criticism of DoD procurement practices. In addition, post 9/11, the heightened focus on security and anti-terrorism measures makes effective compliance a matter of national concern.

But the relevant regulations and statutes intersect in myriad, unexpected ways, as does their enforcement. Multiple agencies with conflicting priorities are involved and lines of jurisdiction are often blurred. Interpretative guidance from the policy makers often leaves you with few resources for figuring out how to best comply. Equally troubling enforcement "wildcatting" often means that an investigation of an export controls violation by one agency may lead to an FCPA investigation by another, and vice versa.

This makes devising an integrated approach to your company's compliance efforts vital. Failure to do so could come at a cost: damage to your company's reputation, diminished share value and potential exposure to significant civil and criminal penalties.

Contents & Contributors


U.S. EXPORT CONTROLS THE REQUIREMENTS, REVIEWS, REALITIES AND MYTHS
Joyce Remington, BAE Systems North America

GLOBAL BUSINESS AND THE CHALLENGES OF ITAR COMPLIANCE
Christopher Wall, Pillsbury Winthrop LLP

EXPORT CONTROLS ENFORCEMENT: CONDUCTING INTERNAL INVESTIGATIONS AND RESPONDING TO VIOLATIONS
Peter Jordan, United Technologies Corporation

MANAGING RISKS IN DEALINGS WITH THE OFFICE OF DEFENSE TRADE CONTROLS COMPLIANCE U.S. DEPARTMENT OF STATE
Philip Rhoads, Attorney at Law

MANAGING FCPA COMPLIANCE: SAIC'S IBRB SYSTEM
Susan M. Frank, Science Applications International Corp.

THE FOREIGN CORRUPT PRACTICES ACT AND THE ARMS EXPORT CONTROL ACT ISSUES AT THE U.S. DEPARTMENT OF STATE
Dale C. Turza, Cadwalader, Wickersham & Taft LLP

FCPA ENFORCEMENT: DEALING WITH VIOLATIONS, DOJ & SEC INVESTIGATIONS AND PENALTIES
Joshua R. Hochberg, U.S. Department of Justice

FCPA ENFORCEMENT: DEALING WITH VIOLATIONS, DOJ & SEC INVESTIGATIONS AND PENALTIES
Stephen Preston, Wilmer Cutler Pickering Hale and Dorr

FCPA COMPLIANCE 2005 UPDATE: MANAGING FCPA RISKS
William F. Pendergast, Dickinson Landmeier LLP

OFAC COMPLIANCE STRATEGIES
John R. Pisa-Relli, U.S. Department of the Treasury

OFAC UPDATE & ISSUES
William B. Hoffman, Davis Polk & Wardwell

U.S. ANTIBOYCOTT COMPLIANCE
Janet Kim, Baker & McKenzie

ENSURING COMPLIANCE THROUGHOUT THE M&A PROCESS
Stephen Yslas, Northrop Grumman Corporation

ANTITRUST COMPLIANCE IN THE M&A PROCESS
Leon Greenfield, Wilmer Cutler Pickering Hale and Dorr

ASSET FORFEITURE & MONEY LAUNDERING SECTION
Lester Joseph, U.S. Department of Justice

DEFENSE TRADE IMPORTS THE OTHER SIDE OF THE FENCE
Erin Crockett, Dresser, Inc.

THE SARBANES-OXLEY EFFECT: RECORD KEEPING, INTERNAL CONTROLS AND DISCLOSURE FOR DEFENSE COMPANIES
F. Joseph Warin, Gibson, Dunn & Crutcher

MITIGATING RISKS AND NAVIGATING INTERDEPENDENCIES
Kathy T. Humenik, The Boeing Company

AN INTEGRATED APPROACH TO DEFENSE INDUSTRY COMPLIANCE
Richard J. Bednar, Crowell & Moring LLP

DUE DILIGENCE AND COMPLIANCE PROCEDURES
Timothy L. Dickinson, Dickinson Landmeier LLP

OVERCOMING CHALLENGES IN DEEMED EXPORT COMPLIANCE
Richard Pettler, Fragomen, Del Rey, Bernsen & Loewy, LLP
Steve Brotherton, Fragomen, Del Rey, Bernsen & Loewy, LLP
James Bartlett, Northrop Grumman Corporation



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